Corporate - Group taxation

Last reviewed - 17 May 2024

Group Taxation

  • No consolidated Corporate Income Tax (CIT) returns for groups.
  • Losses in one group company cannot offset profits in another.

Transfer Pricing

  • Transactions must be at arm's-length; non-compliance can lead to income adjustments and avoidance penalties.
  • Companies must maintain transfer pricing documentation for ten years.
  • Non-compliance penalties can reach ZMW 24 million.

International Compliance

  • From 2021, multinationals with revenues over ZMW 4,795 million must submit Country-by-Country Reports within 12 months post-financial year.
  • Zambia joined the OECD Global Forum to combat tax evasion and enhance financial transparency, committing to EOIR and AEOI standards.

Thin Capitalisation

  • Interest deductibility is limited to 30% of tax EBITDA, excluding turnover tax system businesses and those under the Banking and Financial Services Act.